UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No.

Docket Operations, M-30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

SVP Media Group, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) &(b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), AND 91.417(a) &(b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 25th, 2016

SVP Media Group, LLC c/o Christopher R. Eiffert, Owner 5901 Lafreniere St. Metairie, LA. 70001
504-913-3235TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS ..........................................................................3 SU M MARY ................................................................................................................ 4 INTRODUCTION AND INTERESTS OF PETITIONER .............................................4 BACKGROUND........................................................................................................5 BASISFOR PETITION ...............................................................................................5

A. NAME AND ADDRESS OF PETITIONER ..............................7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SVP Media Group, LLC SEEKS EXEMPTION .............. 8

C. THE EXTENT OF RELIEF SVP Media Group, LLC SEEKS AND THE REASON SVP Media Group, LLC SEEKS THE RELIEF ........................................................................11

D. THE REASONS WHY GRANTING SVP Media Group, LLC's REQUEST WOULD BE IN THE PUBLICINTEREST ..........................................................................13

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ................................ 15

THE REASONS WHY GRANTING AN EXEMPTION FROM THE REQUIREMENTS OF 61.113(A) AND (B) WOULD NOT ADVERSELY AFFECT SAFETY .............................................. 21

CONCLUSION......................................................................................................... 23 2

EXHIBITSGLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of2012 (FMRA) SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System sUAS Small Unmanned Aircraft System (under 55 pounds Gross Weight) VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing DJI UAV manufacturer ESC Electronic speed control FPV First Person View LI-PO Lithium Polymer battery RCV Radio Controlled vehicle 3SUMMARY

SVP Media Group, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) &(b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b), to operate an Unmanned Aircraft System pursuant to Section 333of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit SVP Media Group, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for marketing, real estate photography, commercials, special events, wedding cinematography, documentaries, and landscape inspections over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Christopher R. Eiffert, and I am the owner of SVP Media Group, LLC.

I am a professional videographer and photographer that offers high quality services to the community including wedding videography, real estate photography, marketing videos for small to medium businesses on a budget, event photography, documentaries, training videos for small to medium businesses, and historian photography and videography services for several mardi gras parade groups. My wife and I provide highest quality of customer service and projects management for our clients and strive to present an end product that our customers are pleased with.

I have over 10 years of experience as a photographer, videographer, audio engineer, and graphic designer. I have also been operating a drone as a hobbyist for about one yeai

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.
I have worked in the high tech industry for over 20 years as an electronics technician, research & development technician, quality inspection manager, IT support technician, systems administrator, network engineer, computer software engineer, and a data solutions engineer, all with fortune 500 companies.

The objective of SVP Media Group, LLC's aerial video and photography operations is to provide high quality imaging for a variety of business needs including: weddings, company marketing materials, company training, real estate, land inspections, documentaries, and music videos. SVP Media Group, LLC will also provide knowledge of UAS to others and promote safe UAS operations.BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional

SVP Media Group, LLC seeks an exemption to operate the DJI Phantom 3 Professional UAS for compensation or hire within the NAS. The DJI Phantom 3 Professional UAS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone devices. The DJI Phantom 3 Professional UAS has a maximum gross weight of approximately 2.81b, while having a diagonal dimension of 23.2in, and a maximum speed of 3.9in / 10cm vertical and 3.3ft / 1 m horizontal. DJI Phantom 3 Professional UAS is equipped with four main rotors; driven by electric motors powered by a Lithium Polymer battery. The DJI Phantom 3 Professional UAS that will be operated by SVP Media Group, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with14 C.F.R. Part 45, Identification and Registration Markings.

BASIS FOR PETITION

Petitioner, SVP Media Group, LLC, pursuant to the provisions of the Federal Aviation Regulations (14C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 Professional UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) &(b), 917(a), 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, SVP Media Group, LLC operation of DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, SVP Media Group, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417 (a) &(b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

SVP Media Group, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. SVP Media Group, LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional. Instruction Manual). Furthermore, SVP Media Group, LLC will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.3

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by SVP Media Group, LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

SVP Media Group, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 Professional UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, SVP Media Group, LLC submits that he will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft are in a condition for safe flight.

SVP Media Group, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Professional UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with SVP Media Group, LLC operation of the DJI Phantom 3 Professional UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, SVP Media Group, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. SVP Media Group, LLC submits that safety will not be affected by operation of the DJI 3 Professional UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.In accordance with 14 C.F.R. § 11.81, Christopher R Eiffert provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: SVP Media Group, LLC Christopher R. Eiffert, Owner 5901 Lafreniere St Metairie, LA. 70001 504-913-3235 Ceiffert35(aDyahoo.com ceiffert@svpmediagroup.comB. The Specific Sections Of 14 C.F.R. from Which SVP Media Group, LLC Seeks

Exemption.

1. SVP Media Group, LLC Seeks Exemption From The Requirements Of Section 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, Subsections (a) and (b) prescribe the following, in relevant part:

a. No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

b. A private pilot may, for compensation or hire, act 

### as PIC of an aircraft in connection with any business or employment if —

i. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire.

2. SVP Media Group, LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. SVP Media Group, LLC Seeks Exemption From The Requirements Of Section 91.121.

a. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a) (1) (i) of this section, the current reported altimeter setting of an appropriate available station;

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 34. SVP Media Group, LLC Seeks Exemption From The Requirements

Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. SVP Media Group, LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a) states the following: Each owner or operator of an aircraft:

a. Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

6. SVP Media Group, LLC Seeks Exemption From The Requirements Of Section 91.407(a)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration;

a. Subsection (a) (1), states the following: No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under §43.7 of this chapter

7. SVP Media Group, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

a. Section 91.409, entitled Inspections, subsection (a), states the following:

Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had —

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.8. SVP Media Group, LLC Seeks Exemption From The

Requirements Of Sections 91.417(a) And 91.417(b).

a. Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

i. Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100 hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

(a) A description (or reference to data acceptable to the Administrator) of the work performed; and

(b) The date of completion of the work performed; and

(c) The signature, and certificate number of the person approving the aircraft for return to service.

Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. 10(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

b. The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for I year after the work is perFormed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief SVP Media Group, LLC Seeks And The Reason SVP Media Group, LLC Seeks The Relief.

1. Relief From Section 61.113(a) And (b):

a. Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, SVP Media Group, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional UAS exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, SVP Media Group, LLC submits that all flights of the DJI Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to SVP Media Group, LLC business; and (2) will not carry passengers or property for compensation or hire.

b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 11FyJ

extent required to allow SVP Media Group, LLC to determine that flight by ensuring that the UAS is in compliance with the operating documents (i.e., SVP Media Group, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI DJI Phantom 3 Professional UAS Instruction Manual). SVP Media Group, LLC seeks the requested relief because the DJI Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F R. Part 21, Subpart H. Therefore, SVP Media Group, LLC will ensure that the DJI Phantom 3 Professional UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional UAS User Manuals; prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), SVP Media Group, LLC seeks the requested relief because the DJI Phantom 3 Professional UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

c. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of approximately18minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. SVP Media Group, LLC seeks the requested relief because without an exemption from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 3 Professional UAS will severely constrain the practicality of any aerial video or still photo flight operations that SVP Media Group, LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 Professional UAS operating documents, and the operating limitations proposed by SVP Media Group, LLC, ensure that SVP Media Group, LLC will safely operate the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

d. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) only13

apply to aircraft with an airworthiness certificate, SVP Media Group, LLC requests relief from these Sections because the DJI Phantom 3 Professional UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, SVP Media Group, LLC will use trained technicians to perForm maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., SVP Media Group, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional UAS Instruction Manual). Furthermore, SVP Media Group, LLC will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

D. The Reasons Why Granting SVP Media Group, LLC Request Would Be In The Public Interest: That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing SVP Media Group, LLC LLC to safely, efficiently, and economically perForm aerial video and photography of construction sites, real estate, landscape, over certain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide significant benefits to the economy. Notably, the benefits of SVP Media Group, LLC proposed operation of the DJI Phantom 3 Professional UAS will be realized without conflicting with or violation of any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. DJI Phantom 3 Professional UAS is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perForm aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 Professional UAS does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 Professional UAS.14

Conducting aerial media acquisitions with the DJI Phantom 3 Professional UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video DJI Phantom 3 Professional UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography which burn approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS, while reducing the carbon footprint of aerial acquisitions, also eliminate noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 Professional UAS (weighing approximately 2.8 Ib at their maximum gross weights with a diagonal length of 23.2in / 590mm, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximatelym6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

2. Performing Aerial Video and Photography Operations With DJI Phantom 3 Professional UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of DJI Phantom 3 Professional UAS will allow United States based companies, such as SVP Media Group, LLC to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS utilizes technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 Professional UAS, companies such as SVP Media Group, LLC can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 Professional UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.15

Similar to the manned aerial media acquisition flight operations that have been conducted for decades, SVP Media Group, LLC proposed operation of the DJI Phantom 3 Professional UAS would not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated only in compliance with operating documents (i.e. SVP Media group, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional UAS Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which SVP Media Group, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

2. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, SVP Media Group, LLC's operation of the DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

a. In General. --Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

b. Assessment of Unmanned Aircraft Systems. --In making the determination under subsection (a), the Secretary shall determine, at a minimum.

Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for16

the operation of unmanned aircraft systems identified under paragraph (J).

c. Requirements for Safe Operation. --If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, SVP Media Group, LLC submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS, (b) the pilot certification requirement and (c) the specific operating limitations.

i. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

ii. Technical Specifications Of The DJI Phantom 3 Professional UAS.

The DJI Phantom 3 Professional UAS Specifications and Data Sheet, attached hereto as Exhibits A, set the technical specifications of DJI Phantom 3 Professional UAS forth.

iii. The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable The sUAS To Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Professional UAS as well as other information can be located in the user manual at the following: http://www.dwi.com/product/phantom-3-pro/info#downloads

Technical specifications can also be located at Appendix A.

iv. The DJI Phantom 3 Professional UAS Is Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional UAS do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e.,17

failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the "return to Home" feature can be located in the user manual at the following location: hftp://www.d'i.com/product/phantom-3-pro/info#downloads

v. The DJI Phantom 3 Professional UAS Ground Control Station ("GCS") And It's Operation.

A complete description of the operation and specifications of the DJI Phantom 3 Professional UAS and flight control software can be located at the following location: hftp://Www.dwi.com/r)roduct/phantom-3-pro/info#downloads

vi. Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

vii. SVP Media Group, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 Professional UAS. Additionally, a safety observer will assist all pilots during flight time.

viii. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, SVP Media Group, LLC proposes to commercially operate the DJI Phantom 3 Professional UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft sUAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. AII altitudes reported to ATC must be in feet AGL.18

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. AII operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perForm any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f or safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been perFormed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. AII maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts19

the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections

17. The PIC must possess at least a private pilot certificate and at least a current third-class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes of training the operator's PICs are permitted under the terms of the exemption However, training operations may only be conducted during dedicated training sessions During training, proficiency, and experience building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. AII operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter20

of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a pre-determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. AII operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. AII aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.21

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a)

32. AII operations shall be conducted over private or controlled access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov

. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

SVP Media Group, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering SVP Media Group, LLC's proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Ecemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 Professional UAS, SVP Media Group, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for SVP Media Group LLC's specific proposed flight operations. The FAA has previously granted22

relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). SVP Media Group LLC LLC will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062,11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during SVP Media Group, LLC's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a sUAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight hour requirements in Exemption no. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior to documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, SVP Media Group, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum fluight-Ohour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in 

## a manner consistent with the exemption, including evasive and emergency23

maneuvers and maintaining appropriate distances from people, vessels, vehicles, and
structures.

CONCLUSION

SVP Media Group, LLC seeks an exemption pursuant to 14 C.F. R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing SVP Media Group, LLC to safely, efficiently, and economically operate the DJI Phantom 3 Professional UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, SVP Media Group, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.T Sections 61.113(A) §(b), 91.7(a), 91.121, 91.151 (B), 91.405(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a)&(b), and permit SVP Media group, LLC to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: January 25, 2016

Submitted by:

SVP Media group, LLC



## ?AVEXHIBIT A

DJI Phantom Professional 3

TECHNICAL SPECIFICATIONS

SVP Media Group, LLC only utilizes safe and reliable sUAS. DJI is an industry leader in small UAS production. DJI sUAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also he set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Phantom 3 Professional

1.1 Aircraft 1.1.1 Supported Battery -DJI 5,4480 mAh, 68Wh, LiPo Battery 1.1.2 Weight (Battery & Propellers Included) 1280g 1.1.3 Hover Accuracy (Ready to Fly) Vertical: +/- 0.1 m(when Vision Positioning is active) or +/- 0.5 m, Horizontal: +/- 1.5 m 1.1.4 Max Yaw Angular Velocity 200°/s 1.1.5 Max Tilt Angel 35 0 1.1.6 Max Ascent / Descent Speed: Ascent 5m/s Descent 3m/s 1.1.7 Max Flight Speed-16m/s (NOT RECOMMENDED)

1.2 Gimbal 1.2.1 Working Current -Static: 750mA; Dynamic: 900mA 1.2.2 Control Accuracy -±0.03 0 1.2.3 Controllable Range -Pitch: -90 0 to +30 0 1.2.4 Maximum Angular Speed Pitch: 90°/s

1.3 Camera 1.3. 1 Operating Temperature Range 0°C to 40°C 1.3.2 Sensor Size '/z.3" 1.3.3 Effective Pixels: 12.8 Megapixels 1.3.4 Resolution 4000x3000px 1.3.5 HD Video Recording: 1080p 30 & nop 1.3.6 Recording Field of View: 110 0 185 0

AII specifications can be found in the attached user manual or at: http://www.d'i.com/product/phantom-3-pro/info 24